If your company operates a share or share option plan for employees or office holders (including directors and company secretaries), or if individuals have acquired shares or other securities in the company, you are required to report the relevant transactions to HMRC on an annual basis. All reporting for the tax year ending 5 April 2026 must be submitted via HMRC’s Employment Related Securities (ERS) online service (part of the PAYE for Employers service).

All annual returns must be filed by 6 July 2026.

Enterprise Management Incentive (EMI) options - notification changes

EMI options must be notified to HMRC by 6 July following the end of the tax year in which they are granted, replacing the previous 92-day deadline.

This is separate from the annual ERS return and must be completed using HMRC’s EMI notification templates. Failure to notify EMI options on time can result in the options not qualifying for EMI tax advantages.

For other tax-advantaged schemes (such as Share Incentive Plan (SIP), Company Share Option Plan (CSOP) and Save As You Earn (SAYE)), the scheme itself must be registered with HMRC by 6 July following the end of the tax year in which it commenced. Failure to register may result in the loss of tax-advantaged status.

What needs to be reported?

Once a scheme is registered, an annual ERS return must be submitted for each scheme, regardless of whether there has been any activity.

This includes:

• Shares or securities acquired by employees, directors or office holders

• Options granted, exercised, lapsed or cancelled

• A nil return where there has been no activity

• A final return where a scheme has ceased

Companies (including LLPs) that are part of international groups must also identify and report instances where employees receive shares in overseas group companies.

Late filing penalties will automatically apply for non-compliance and crucially as mentioned above approved share schemes may lose any eligible tax advantages if they have not been registered online by 6 July 2026. HMRC no longer issue notices to file or paper reminders for share schemes.

Practical points

HMRC have indicated that registering a scheme on the ERS online service can take up to two weeks, so early action is recommended to avoid delays.

Registration is generally a one-off requirement per scheme, so only new schemes implemented in 2025/26 need to be registered by 6 July 2026.

Get in touch

Our Business Tax team can assist with ERS registrations, annual filings, and the self-certification of tax-advantaged share schemes. If you have questions about any of these schemes, please complete the form below.